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Volume XV, No. 11
Wednesday, October 7, 2026
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 Note from David R. Adams:
Do you have a situation? We love situations. Give us a call, send an email, drop by; we truly enjoy solving complex Labor Law and Risk Transfer issues.
Welcome to October, where the morning dog walk goes from enjoyable in shorts to, “Where did I put my vest?” and occasionally, “Where in the world is my coat?” Here in Buffalo, we love our seasons—all six of them: Summer, Fall, Winter, Spring, Hockey, and Football.
It also means that the courts are back in full swing, and we have some great cases for you.
This month, we have two cases of sufficient importance that we will address both in our monthly webinar.
First, from the First Department we will examine Hearns v Blended Family LLC where the court held that drilling holes through two separate walls to run a cable was not an “alteration” and that thus § 240(1) did not apply. This is in contrast to the long-standing rule set forth in Joblon v Solow. We will address what constitutes an alteration to qualify for the application of the § 240(1) and liability against the owner, contractor and agents.
Second, we will analyze Veliu v Verizon, where the First Department found a question of fact where the plaintiff was the foreman on the job and was injured because sufficient bracing was not added to a trench, which then collapsed, injuring him. The court held that he, as foreman, could have directed workers to use available wood to brace the trench and thus there was a question of fact as to the sole proximate cause defense. The remaining question was simply whether he knew he was expected to use the wood to brace the trench.
For more information and to register, click here.
These are two cases we will be seeing, and using, in summary judgment motions for years to come.
Now, on to the photos for the month. This photo was taken on my morning dog walk. What we have is a condo building where the brick needed to be repaired at some height above the ground. The owner asked the management company to hire a contractor to repair the brick. The management company hired a local masonry company to do the repair and was asked by the masonry contractor to also hire a scaffold company to erect the scaffold. The scaffold company sent out a crew to set up a scaffold and, when it was set up, the masonry contractor sent out their crew to do the repair. As the ground was not even, the scaffold set up crew had to put wood under one leg of the scaffold. When the masonry crew arrived, they checked over the scaffold, found it to be safe, and climbed up on the ladder and started working. Of course, as in every good § 240(1) story, the wood under the foot of the ladder gave way, the scaffold shifted and the plaintiff fell and was injured. § 240(1) case and what else is available here?
Let’s start with the § 240(1) case. The plaintiff was a person so employed and thus a valid plaintiff. The owner of the property and the management company will be appropriate defendants, the owner is, of course the owner, and the management company will be considered an agent as they hired the contractors. The overall job was a repair, and enumerated task, and the injury was caused by a height differential and the effect of gravity. Textbook § 240(1).
That said, plaintiff can also sue the scaffold company for § 240(1), and the results of their defense, based on their lack of status as a defendant are not entirely clear. The argument would be that they were an agent of the owner and such a claim requires that the scaffold company "has been delegated to a third party, that third party then obtains the concomitant authority to supervise and control that work and becomes a statutory 'agent' of the owner or general contractor" (Russin v Louis N. Picciano & Son, 54 NY2d 311, 318, 429 N.E.2d 805, 445 N.Y.S.2d 127 [1981]). In this instance, the scaffold company would "qualify as statutory agents only with regard to injuries 'sustained in those areas and activities within the scope of the work delegated to [them]'" (Burns v Lecesse Constr. Servs. LLC, 130 AD3d 1429, 1432, 12 N.Y.S.3d 722 [4th Dept 2015]). Where, as here, the scaffold contractor did not have authority to supervise or control the work of the mason, the injury producing work is not sufficient to establish § 240(1) liability as an agent.
The plaintiff’s negligence claim would likewise be dismissed as the scaffold contractor did not supervise, direct or control the injury producing work.
That’s it for this month. Enjoy the start of fall and we will see you next month.
As always, please feel free to reach out with any question Labor Law or Risk Transfer related; we are happy to assist.
-David
Hurwitz Fine P.C.
The Liberty Building
424 Main Street, Suite 1300
Buffalo, New York 14202
Phone: 716.849.8900
Fax: 716.855.0874
Email: [email protected]
Labor Law Pointers is published the first Wednesday of each month. If you know of others who may wish to subscribe to this free publication, please feel free to forward it. If you wish to subscribe or unsubscribe, please send an e-mail to [email protected] or call the Editor/Labor Law Team Leader David R. Adams directly at (716) 849-8916.
Don’t forget to subscribe to our other publications:
Coverage Pointers: This twice-monthly electronic newsletter summarizes important insurance law decisions from appellate courts in New York State with the occasional snapshot across borders. Coverage Pointers, the electronic newsletter that started it all, continues to offer guaranteed publication every other Friday, and a read-at-a-glance summary of important decisions as they happen. Contact Dan Kohane at [email protected] to subscribe.
Medical & Nursing Home Liability Pointers: Medical & Nursing Home Liability Pointers provides the latest news, developments, and analysis of recent court decisions impacting the medical and long-term care communities. Contact Liz Midgley at [email protected] to subscribe.
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September 10, 2026
Appellate Division, First Department
Memorial Sloan-Ketting (“MSK”) owns the property where plaintiff’s injuries occurred. MSJ hired JGN as a general contractor to complete a renovation project for new offices in the building and JGN hired ADCO as a subcontractor to perform demolition on one of the floors being renovated.
Plaintiff was an electrical apprentice at ADCO and had been working at the building for about two months prior to his accident. Plaintiff’s duties included pulling and connecting electrical wires and roughing out rooms. Plaintiff received his work instructions from a foreman also employed by ADCO.
On the date of the incident, plaintiff exited the third floor after performing electrical work and headed toward the staircase to go outside for a break. While descending the stairs and holding the railing on the left-hand side, he slipped on the second step from the bottom, missed the last step, and fell down on his knee. Plaintiff observed dust all over the stairs and that the staircase was “beat up.” There was no grip on the stairs and the metal was showing through the paint. Plaintiff sued under common law negligence and Labor Law 200, 240(1), and 24(1).
 Labor Law § 240(1) (RHF)
The appellate division reversed the lower court’s ruling and granted plaintiff’s motion for summary judgment on Labor Law §240(1) finding that a permanent stairway can be a safety device where it is the sole means of access to other floor(s) especially where the stairs are worn out or missing.
PRACTICE POINT: Investigating and understanding facts from the time of the accident through depositions is critical for successful motion practice. Any notion that the mere existence of permanent stairway will shield a defendant from §240(1) liability is erroneous. For the purpose of crafting a summary judgment motion where an accident involved a permanent stairway, being able to establish that there were other means “available” will be useful in distinguishing this case.
Here, the First Department unanimously reversed the trial court and found that there was a violation of §240(1) even though the accident occurred on a permanent stairway. The court pointed out that the statute protects workers from gravity related hazards posed by permanent stairways that “provide the sole means of access to the floors of the building”. (Citing Gory v. Neighborhood Partnership Housing Dev. Fund Co., Inc., 113 A.D.3d 550 (1st Dept. 2014).
 Indemnity Issues in Labor Law (AMC)
The Appellate Division held that the indemnification clause in the subcontract between JGN and ADCO was triggered because Plaintiff's claims arise out of ADCO's work. As such, JGN is only conditionally entitled to contractual indemnification to the extent the accident was not proximately caused by its negligence. The Court further held that in light of this conditional grant of contractual indemnification, ADCO's arguments concerning the common-law indemnification and contribution claims against it are academic.
Plaintiff, a telecommunications field technician employed by nonparty Verizon, alleged that he was injured while he was installing wi-fi services at a mixed-use building. The premises were owned by Abeken, which leased the commercial portion of its basement to Blended Family for operation of a daycare center. The lease did not include the basement on the residential side of the building, which contained a superintendent’s office, storage room, sprinkler room, and telecommunications equipment room. The basements for the residential and commercial sides of the building were contiguous but there was no door connecting them. Each basement was separately accessed from outside the building. Blended Family hired Verizon to provide it with wireless internet service.
Plaintiff testified that he proceeded to Blended Family’s space when he arrived at the building. Upon inspection, he determined that the router would be located inside its leased basement space and would be connected by wire to the building’s Verizon router, which was in the telecommunications room on the residential side of the building. Abeken’s superintendent unlocked the basement from the outside and escorted plaintiff in. To connect the router, plaintiff needed to drill a hole in the wall between Blended Family’s space and the basement hallway and then a hole in the wall between the hallway and the Verizon equipment room to feed the cable through and back into the drop ceiling. Plaintiff set up one of his two ladders inside Blended Family’s space and the other in the telecommunications room. Plaintiff asked to use the building’s ladder to set up in the basement hallway. Plaintiff testified that the superintendent allowed him to use the building’s ladder, but the superintendent denied doing so.
Plaintiff began feeding the wire through the drop ceiling while standing on the building’s ladder. While pulling the cable, Plaintiff felt the ladder shift to the right and fall over causing Plaintiff to fall as well. Plaintiff did not observe any defects or problems with the ladder before or after his accident.
The superintendent testified that he allowed Plaintiff into the telecommunications room and remained outside during the whole time Plaintiff performed his work. He testified that after Plaintiff completed his work, he locked the door to the telecommunications room and walked Plaintiff out.
Labor Law § 240(1) (RHF)
The First Department unanimously affirmed the dismissal of plaintiff’s §240(1) cause of action upon the grounds that the work being performed was not construction related activity as defined by the statute.
PRACTICE POINT: With respect to the applicability of the statute, the court dismissed plaintiff’s Labor Law §240(1) claim. The First Department held that plaintiff’s work which included drilling two holes to accommodate the running of cable lines did not constitute and “alteration”.
This holding seems to be at odds with the Court of Appeals decision in Joblon v. Solow, 91 N.Y.2d 457 (1998). In Joblon, New York’s highest court granted summary judgment to the injured plaintiff where the worker similarly had to drill a hole through a concrete wall to run a cable through it and was caused to fall off a ladder during that process. In Joblon, the Court of Appeals found that the work constituted a “significant” physical change to the building or structure. The Joblon court did acknowledge that “although the question is close – the work performed by Joblon was a significant physical change”. Thus plaintiff’s §240(1) motion was granted. It appears that the Hearns court may have relied on the Court of Appeals admission that “the question is close” when determining the applicability of the statute. Emphasizing how minimal the alleged alteration can be accomplished through deposition testimony and affidavits where necessary.
Indemnity Issues in Labor Law (AMC)
The First Department unanimously affirmed the Trial Court’s decision granting Abken’s conditional contractual indemnification against Blended. The Appellate Division found that the indemnity provision was triggered because the claim arose by reason of work performed at the request of Blended Family; that the indemnification provision is not void despite there being questions of fact as to Abeken’s liability; and Blended’s argument that it is not a sophisticated entity, and thus the indemnification provide should be void pursuant to GOL 5-321, is unpersuasive and unpreserved.
Plaintiff, a carpenter, alleges that he was injured when he tripped on a torn and crumpled portion of tarp that covered a corridor as he was pushing an A-frame cart to deliver glass windows to newly constructed offices in an office renovation project. Defendant 900 Third Avenue, a subsidiary of Paramount Group, Inc,, owned the building and defendant/third-party plaintiff Gannon Contracting, LLC served as the GC on the renovation project. Third-party defendant Empire Office, Inc., plaintiff’s employer, was the subcontractor performing office-framing and glass work on the project.
 Labor Law § 241(6) (MRV)
Plaintiff was entitled to summary judgment as a matter of law on his 241(6) claim predicated on a violation of NYCRR 23-1.7(e)(1) because the evidence demonstrated that plaintiff fell on a tripping hazard in a passageway. Deposition testimony of witnesses at the scene and photographs of the location taken minutes after the accident establish that plaintiff’s injuries were proximately caused by a hazardous condition in the corridor, which was the inadequately secured and wrinkled tarp placed on carpeting. Gannon’s foreman conceded that the condition of the tarp depicted in the photographs was a tripping hazard. Gannon’s foreman also conceded that Gannon was the entity that placed the tarp in the corridor. The deposition testimony and photographs make clear that the location was a passageway, not an open floor space, and therefore is governed by 12 NYCRR 23-1.7(e)(1).
Plaintiff alleged that he sustained injuries when working on a construction site as a foreman and “pitman” for nonparty De-Bar Company Construction Corporation. Specifically, he stated that he was assigned to work as the pitman and was responsible for working in the trenches. Plaintiff stated he was required to be positioned inside the trench and close to the backhoe while directing the backhoe operator because the operator did not have an unobstructed view of the area under the backhoe’s bucket. At the time of the accident, plaintiff was standing in an area of the trench that was three to four feet deep when a large piece of concrete curb that was being hoisted several feet into the air rolled out of the backhoe’s bucket and struck plaintiff’s leg. One of plaintiff’s coworkers witnessed the accident and averred that a piece of concrete curb overlay became detached from the underlying curb and sidewalk as part of the excavation work, slid into the trench where plaintiff was standing, and stuck plaintiff’s leg.
Labor Law § 240(1) (RHF)
The First Department reversed the lower court (with one dissenting jurist) and denied plaintiff’s motion for summary judgment on §240(1) finding a question of fact as to whether plaintiff knew or should have known that the trench should have been braced and that lumber was available to provide such bracing.
PRACTICE POINT: Always point out to the court where there are multiple versions of the accident, especially where one version calls into question the applicability of §240(1). In this case, plaintiff’s version of the accident which described a piece of concrete falling from a backhoe bucket while being hoisted out of the trench would have amounted to a violation of §240(1) according to the majority and the dissenting justice. The majority concluded, however, that the accident description by plaintiff’s co-worker creates a factual issue as to the applicability of §240(1).
Plaintiff’s co-worker denies that the concrete fell during the hoisting process. Instead, the co-worker stated that the piece of curb overlay in question became dislodged on its own and slid into the trench. This testimony together with proof that trench bracing was on site and available for plaintiff use. In fact, there were sections of bracing being utilized in other areas of the trench the use of which would have prevented plaintiff’s accident.
This proof of safety devices (shoring/bracing, etc.), plaintiff’s knowledge of its availability and the co-workers alternative factual account were not enough, however, for the court to grant defendant’s §240(1) summary judgment motion. Gratuitously, the court note that a trench depth of at least two feet was not de minimus.
56th Realty, LLC (owner) moved for summary judgment on its cross-claim against defendant Puca Construction Corp. for contractual indemnification. The lower court granted 56th Realty’s motion. Puca argued that General Obligations Law 5-322.1(1) prevents summary judgment because there are issues of fact as to whether the negligence of Owner’s agents contributed to plaintiff’s accident. Owner argued there was no support for any connection between it and its agents’ work.
Indemnity Issues in Labor Law (AMC)
The First Department reversed the Trial Court’s decision granting Owner’s motion for contractual indemnification against Puca Construction Corp. The Appellate Division held that there is an issue of fact as to whether Glenwood or York were negligent in causing Plaintiff’s injuries. And, additionally, since there is a question of fact as to whether Glenwood or York were agents of the Owner, and whether Glenwood’s or York’s negligence caused Plaintiff’s accident, contractual indemnification of the Owner would be prohibited.
In February 2021, the plaintiff allegedly was injured while working at a construction site owned by the defendant New York City School Construction Authority in Brooklyn. At approximately 4:00 p.m., the plaintiff allegedly entered the cockpit of a compact track loader or "skidsteer" on site to prepare it for use during the rest of his shift, since he was anticipating, among other things, inclement weather. The plaintiff testified at a hearing pursuant to General Municipal Law § 50-h and his deposition that as he was exiting the cockpit, he slipped on an icy step located on the compact track loader and fell approximately three feet to the ground. The Supreme Court granted that branch of the defendants' motion which was for summary judgment dismissing the cause of action alleging a violation of Labor Law § 240(1), denied the remainder of the motion, and denied the plaintiff's cross-motion.
 Labor Law § 240(1) (PCSM)
On appeal, the Second Department affirmed dismissal of the plaintiff’s Labor Law § 240(1) claim. The court held that the plaintiff's descent did not present a physically significant elevation differential, and the injury was not caused by the failure to provide protection against an elevation-related risk covered by the statute. The court therefore rejected both the plaintiff’s challenge to dismissal and his request for summary judgment on liability.
PRACTICE POINT:
In defending a Labor Law § 240(1) claim arising from a short fall, focus on the source of the risk, not just the distance fallen. In cases involving a worker’s descent from equipment, develop a clear record of the accident mechanism, the height and nature of the elevation differential, and whether the injury resulted from the absence or inadequacy of a statutory safety device.
Labor Law § 241(6) (MRV)
The Second Department held that the lower court properly denied defendant’s motion for summary judgment seeking dismissal of the 241(6) claim predicated on 12 NYCRR 23-1.30. Neither the defendants nor plaintiff eliminated triable issues of fact as to whether the defendants sufficiently complied with the requirements of 12 NYCRR 23-1.30 or whether the alleged violation of this Industrial Code provision was a proximate cause of the accident.
However, the lower court should have granted defendant’s motion seeking dismissal of the 241(6) claim predicated on 12 NYCRR 23-1.7(d). Plaintiff’s deposition testimony established that he slipped on the compact track loader’s step so 23-1.7(d) did not apply to this case because the steps are not a floor, passageway, walkway, scaffold, platform, or other elevated work surface.
Labor Law § 200 and Common-Law Negligence (AMC)
The Second Department held that the Trial Court properly denied Defendants’ motion for summary judgment pursuant to §200/common-law negligence. Defendants failed to establish: at which time the storm stopped, if at all, in relation to Plaintiff’s accident; whether they had actual or constructive notice of the alleged dangerous condition and whether there had been enough time to take remedial measures.
Further, the Appellate Division rejected Defendants’ argument that Plaintiff’s failure to see the ice on the step prior to his fall did not establish the cause of Plaintiff’s accident without engaging in speculation. Finally, the Appellate Division found triable issues of fact as to whether Plaintiff was authorized to operate the compact track loader at the time in question and as to whether his actions were the sole proximate cause of the accident.
The plaintiff commenced this action against the defendants South Conduit Property Owner, LLC, and March Construction/Consulting, to recover damages for personal injuries the plaintiff alleged that she sustained while working at a construction site owned by South Conduit and managed by March Construction. According to the complaint, at the time of the incident the plaintiff was working at the construction site cleaning a parking area. While sweeping on the ground floor, she saw a piece of wood that she believed was debris, picked it up, unknowingly uncovering an approximately 10-foot deep hole, and fell into the hole, sustaining injuries. The plaintiff alleged, inter alia, that the defendants violated Labor Law 240(1) and 241(6) The plaintiff moved, among other things, for summary judgment on the issue of liability on the cause of action alleging a violation of Labor Law § 240(1) and so much of the cause of action alleging a violation of Labor Law § 241(6) as was predicated upon a violation of 12 NYCRR 23-1.7(b)(1)(i) insofar as asserted against the defendants. The defendants opposed. The Supreme Court, denied those branches of the plaintiff's motion.
Labor Law § 240(1) (PCSM)
On appeal, the Second Department affirmed the denial of the plaintiff’s motion for summary judgment on liability under Labor Law § 240(1). Although the plaintiff made a prima facie showing of a statutory violation after falling into a 10-foot hole, the defendants raised a triable issue as to whether her conduct was the sole proximate cause of the accident. Their evidence indicated that the hole had been covered by a braced, 50-pound wooden cover marked “HOLE,” and that the plaintiff had been instructed not to move construction materials.
PRACTICE POINT:
A sole proximate cause defense under Labor Law § 240(1) requires evidence connecting the plaintiff’s conduct to the accident and showing that adequate protection was available. Here, evidence that the opening was covered by a heavy, braced cover marked “HOLE,” and that the plaintiff had been instructed not to move construction materials, raised a triable issue as to whether she moved the cover and exposed the hazard. Preserve evidence of the safety device’s condition and placement and document any instructions given to the worker.
Labor Law § 241(6) (MRV)
12 NYCRR 23-1.7(b)(1)(i) mandates that every hazardous opening into which a person may step or fall be guarded by a substantial cover fastened in place or by a safety railing. The evidence submitted by plaintiff established her prima facie entitlement to judgment as a matter of law on liability under 241(6) predicated upon a violation of 12 NYCRR 23-1.7(b)(1)(i). However, plaintiff’s motion was properly denied because defendants raised a triable issue of fact in opposition.
The plaintiff allegedly was injured while working in an apartment building owned by the defendant. The plaintiff alleged that he was applying a finishing coat of plaster to the ceiling when a ladder he was using moved and he fell. In January 2020, the plaintiff commenced this action against the defendant to recover damages for personal injuries, alleging a violation of Labor Law § 240(1). The plaintiff subsequently moved for summary judgment on the issue of liability on the cause of action alleging a violation of Labor Law § 240(1). The Supreme Court denied the plaintiff's motion
Labor Law § 240(1) (PCSM)
On appeal, the Second Department reversed the denial of the plaintiff’s motion and granted summary judgment on liability under Labor Law § 240(1). The plaintiff was applying plaster to a ceiling when the ladder he was standing on moved for no apparent reason, causing him to fall. This evidence established that the ladder failed to provide proper protection and that the failure proximately caused his injuries; the defendant failed to raise a triable issue of fact.
PRACTICE POINT:
In cases involving falls from ladders, discovery should pinpoint what caused the ladder to move. Evidence that a ladder shifted or tipped for no apparent reason may support liability under § 240(1), while evidence that the plaintiff merely lost balance, without any indication that the ladder was defective or inadequately secured, may defeat the claim. Develop a clear record of the ladder’s condition, placement, footing, and any steps taken to secure it.
The plaintiff allegedly sustained injuries when he fell from a ladder while performing roofing work at a building owned by the defendant Riverhead Central School District. At the time of the accident, the plaintiff was employed by Dynasty RSW, LLC, and the defendant Stalco Construction, Inc. was the general contractor on the project. The plaintiff alleged that as he descended the unsecured ladder, the ladder shifted, causing him to fall.
The plaintiff commenced this personal injury action against RCSD and Stalco, alleging a violation of Labor Law § 240(1). RCSD commenced a third-party action against Dynasty, seeking, among other things, contractual indemnification. The plaintiff moved for summary judgment on the issue of liability on the cause of action alleging a violation of Labor Law § 240(1). RCSD moved, inter alia, for summary judgment on the third-party cause of action for contractual indemnification. The Supreme Court granted the plaintiff's motion and denied that branch of RCSD's motion which was for summary judgment on the third-party cause of action for contractual indemnification. RCSD and Stalco separately appeal.
Labor Law § 240(1) (PCSM)
On appeal, The Second Department affirmed summary judgment for the plaintiff on liability under Labor Law § 240(1). The court found that the plaintiff’s testimony established that the unsecured ladder shifted as he descended from roofing work, causing him to fall. Because the defendants failed to raise a triable issue of fact, the court held that the ladder’s failure to provide proper protection proximately caused the accident.
PRACTICE POINT:
When a worker alleges that an unsecured ladder shifted and caused a fall, the plaintiff’s testimony may be enough to establish liability under Labor Law § 240(1). Develop evidence about how the ladder was placed and secured, the surface beneath it, and the cause of its movement. Without evidence raising a factual dispute on those points, a defense may not withstand summary judgment.
Indemnity Issues in Labor Law (AMC)
The Appellate Division affirmed the Supreme Court’s decision denying RCSD's motion for contractual indemnification against Dynasty. It held that since RCSD was not a party to the agreement between Stalco and Dynasty or named as an indemnitee therein, RCSD is not entitled to contractual indemnification under that agreement. Additionally, the Appellate Division held that Dynasty would not be bound by an indemnification clause contained in the agreement between RCSD and Stalco, even if the agreement between Stalco and Dynasty incorporated the terms and conditions of the agreement between RCSD and Stalco.
 New York Industrial Code Regulations (EDA)
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Nothing for this month; Eric is out of the country on a well-deserved vacation.
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Labor Law Pointers
Editor
David R. Adams
Associate Editor
Eric D. Andrew
Associate Editor
Patrice C. S. Melville
Associate Editor
Ashley M. Cuneo
Associate Editor
Robert H. Flynn
Associate Editor
Jessica L. Deren
Associate Editor
Marten R. Violante
Labor Law Team
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David R. Adams, Team Leader
[email protected]
Patrice C. S. Melville
[email protected]
Brian F. Mark
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Elizabeth K. Ognenovski
[email protected]
Robert H. Flynn
[email protected]
Joseph P. Mendoza
[email protected]
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